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Rockiedog2

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When I can walk across the clay runway and not sink in.
Another hard storm with lots of rain last night.
Same here Dan. Been tweaking and then sittin waiting on the strip to dry up or the wind quit blowing. If not for that I would have had the list done long ago.
Sorry, didn't mean to get OT
 

Rockiedog2

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Aye, that's the rub. MY interpretation, when I'm feeling appropriately bloody-minded, is that 91.215 and .225 don't apply to homebuilts *at all*.

"...any aircraft which was not originally certificated with an engine-driven electrical system or which has not subsequently been certified with such a system installed..."

The "subsequently certified" must be referring to a Supplemental Type Certificate...from wence, one can assume that "originally certificated" refers to the TYPE CERTIFICATE as well. And, of course, EABs don't have those. All, literally, have not been certificated. Hence, none have been certificated with an engine-driven electrical system.

Was I willing to bet a $10,000 fine on this? Well, no. :)


Actually, that wording is optional (AC65-23A, "...or a similarly worded, statement..."). I've got several in my Fly Baby logs stated as merely, "I find this aircraft airworthy," or "I feel said aircraft is in sound flying condition," "Annual inspection completed this date...ship is airworthy," "I find the aircraft meets that requirements of the certification requested," "Inspection completed this date and found to be airworthy."

All of these are in the older log entries. I suspect that when AC 65-23 came out, most A&Ps just copied the recommended wording ("I certify this aircraft....").

Ron Wanttaja
Maybe 40 years ago the Fed came out with a getoutajail free program. A no jeopardy inspection and "helpful" correction of improper logbook entries. So my paperwork typically not being the best I bit. The nice Fed showed up and looked over my Acrosport 2 logbook. He got visibly agitated when he saw I had copied the wording for the condition inspection but stupidly put "annual" inspection in place of condition inspection. Well, tho agitated, he did his best PR and patiently explained to the stupid builder/mech/PIC and I white outed/corrected it and he initialed it. Some of those guys live in a very small world.
Well, I think the point is that it depends on who you get and what kinda day he's having.
 

Pops

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And there is one Fed out there that will never forget when he was ramp checked. I loved it, I loved it. :)

Added-- He would have to be retired by now.
 

TFF

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The FAA loves it when you call a condition an annual. Love it. If you had an IA, dressing you down would be a lucky outcome. I learned copy the statement in the operating instructions. They can be worded differently through the years so I just copy. If there is a question, I point at that paragraph.

A biplane is good camo for hedging bets on ADSB because it’s not absurd to have no electrical. Play the part.
 

BBerson

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How do I know what it was originally approved with - electrical, starter, generator, etc.???
Do you have records of the weight and balance? That should provide clues of weights of major parts and deduce if it had a starter or generator or battery and location.
 

Pops

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I have posted it before, but will again.
Loafing at the county airport where I was based for 20 years. A white gov car pulls in the parking lot at the same time as a Piper Chieftain landed and taxied to the ramp. As soon as the stairway came down and some people got on the ground the FAA inspector went up the stairs right behind them and to the cockpit were the pilot and co-pilot were still in their seats. Told them that is was a ramp check and needed to see all the paper work. They came out of the airplane and opened the pouch and started spreading papers out on the wing.
I watched all of this and came up and said as serious as I could saying , "Excuse me, but are you driving the white gov car in the parking lot?" He said "Yes , is there something wrong ?" I ask him " where is the auto safety sticker on the windshield ?" He ask " is there supposed to be one on the windshield? I replied with, " do you see any other cars in the parking lot without one?" and maybe you should have one" He said "No" and "Are you a state police ?" I said "NO, Touche' , how do you like being ramp checked?" The two pilots started laughing so hard they could hardly stand up.
His face got red and he went to his car as fast as he could and left in a rush.
 

JRC

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I hope? Is there a portable ADS-B in and out yet? when?
 

TFF

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Portable Out in the US will be a no because how the regulation is written. It would have been nice to have something like FLARM for VFR daytime where there is a warning signal but not ties to an airplane like ADSB is. Too late.
 

mcrae0104

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Aye, that's the rub. MY interpretation, when I'm feeling appropriately bloody-minded, is that 91.215 and .225 don't apply to homebuilts *at all*.

"...any aircraft which was not originally certificated with an engine-driven electrical system or which has not subsequently been certified with such a system installed..."
Is an aircraft with a special airworthiness certificate not certificated?

It seems to me that "originally certificated" vs. "subsequntly-certificated" is a question of chronology, rather than "type-certificated" vs. "certificated" via special airworthiness certificate. I am perfectly willing to be shown otherwise, if supported by the FARs or other FAA interpretation.
 

Wanttaja

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Is an aircraft with a special airworthiness certificate not certificated?

It seems to me that "originally certificated" vs. "subsequntly-certificated" is a question of chronology, rather than "type-certificated" vs. "certificated" via special airworthiness certificate. I am perfectly willing to be shown otherwise, if supported by the FARs or other FAA interpretation.
Yeah, there was a reason I didn't try to use it as an excuse to remove the transponder from my airplane and not install ADS-B. :)

But I just took a couple of minutes to research this. The FAA has three types of "Certification": Type, Production, and Airworthiness.

Found an interesting FAA web page on this subject. It's for Unmanned Aerial Systems, but I think the overall description applies to crewed aircraft as well.

It states that Part 21 says that "Type Certification" refers to ..."approval of the design of the aircraft and all component parts (including propellers, engines, control stations, etc.). It signifies the design is in compliance with applicable airworthiness, noise, fuel venting, and exhaust emissions standards. "

Of "Airworthiness Certification," it says, "...An airworthiness certificate can be either in the Standard or Special class and signifies that an aircraft meets its approved type design (if applicable) and is in a condition for safe operation...."

Now: We have a regulation that specifies EQUIPMENT that must be installed to operate in particular airspace, if the airplane is "certificated with an engine-driven electrical system."

Which is a closer match? Type Certificate, or Airworthiness Certificate?

Type Certification, obviously. It's the one that involves the design of the aircraft and "all component parts." The Airworthiness Certificate concerns itself solely with the airplane as a whole being in a condition for safe operation.

With this logic, NO homebuilt has to carry a transponder or ADS-B unless they actually want to enter Class B, C, or D airspace... because are not originally (type) certificated with an engine-driven electrical system. The fact that 91.215 and 91.225 go on to say, "or not subsequently been certified with such a system installed" reinforces the interpretation that it's referring to the Type Certificate. Because there *are* procedures in place to re-certify airplanes with Type Certificates.

But like I said, I wouldn't have wanted to be the test case on this, sweating with a desk lamp shining in my face while a passel of FAA inspectors wearing fedoras grill me on my interpretation. If someone *does* manage to get away with this argument, you can bet the next update of Part 91 "corrects" the wording.

Ron Wanttaja
 

n6233u

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With this logic, NO homebuilt has to carry a transponder or ADS-B unless they actually want to enter Class B, C, or D airspace...
That is what I was thinking, the definition of airspace is like an upside down wedding cake and my desire is to stay out of the airspace, under the cake like other type certified non-engine driven electrical system aircraft.

But like I said, I wouldn't have wanted to be the test case on this, sweating with a desk lamp shining in my face while a passel of FAA inspectors wearing fedoras grill me on my interpretation. If someone *does* manage to get away with this argument, you can bet the next update of Part 91 "corrects" the wording.

Ron Wanttaja
Exactly, having had to deal with DOT in the trucking industry over the years it really boils down to how the local official interprets the rules. Unless you have a strong compelling reason to change their mind, you'll lose the discussion. Although, I have had conversations with the FAA a couple of times over the years and it usually isn't so bad and I was pleased with the outcomes.

For the record, I love ADSB and all it's benefits, I am just having a hard time installing a $3,000-$5,000 piece of equipment in a $25,000 airplane so I can fly like I used to, under the airspace to local airports because I rarely fly more than 1500' AGL.
 

BBerson

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The actual type certificate paper is held by the manufacturer. All aircraft are required to carry an airworthiness certificate paper and a registration "certificate". So they are heavily certified.

Ultralights are not aircraft and are classed as vehicles by the FAA and so no FAA certificates.

Models and UAS over 9oz have a sort of FAA registration process now.
 
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